Memorandum Opinion
NIMS, Judge:
This case is before the Court on respondent's motion for summary judgment made pursuant to Rule 121.
Respondent determined a deficiency of $7,581.43 and an addition to tax for fraud under section 6653(b) of $3,790.71 with respect to petitioner's Federal income tax for 1979.
The substantive issues are (1) whether petitioner under-reported his 1979 gross income by the amount of ...
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